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Partnerships Franchise Tax Board

Venable LLP

California Nonresidents Selling Partnership Interests Beware: Franchise Tax Board Conflates Federal Gain Recharacterization Rules...

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​​​​​​​Nonresidents of California generally are not taxed by California on gain resulting from the sale of partnership interests. Under new guidance issued by the California Franchise Tax Board ("FTB") nonresidents can now...more

Eversheds Sutherland (US) LLP

Updates from the MTC’s Summer Meetings

​​​​​​​The Multistate Tax Commission (MTC) held its 55th Annual Meeting in Anchorage, Alaska from August 1st through the 4th. During the four-day event, the Audit, Litigation and Nexus Committees met on Monday, the Uniformity...more

Eversheds Sutherland (US) LLP

Updates from the MTC’s Uniformity Committee Spring Meeting

The Multistate Tax Commission (MTC) held its spring meetings in Albuquerque, New Mexico on April 19 through 22. The Uniformity Committee meeting took place on April 20 - some highlights from the meeting are included below.  ...more

Allen Matkins

California Office of Tax Appeals Upholds Taxpayer Friendly "Drop and Swap" Case

Allen Matkins on

On January 28, 2020, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request to rehear In the Matter of the Appeal of Sharon Mitchell (OTA Case No. 18011715). This decision may...more

A&O Shearman

California Enacts New Partnership Audit Rules

A&O Shearman on

On September 23, 2018, Senate Bill 274, Administration of taxes: notice of deficiency assessment (SB-274), was signed into law by Governor Jerry Brown of California. With the enactment of SB-274, California has adapted its...more

Allen Matkins

The FTB’s “Doing Business” Trap For Foreign LLCs With California Managers, Members Or Agents

Allen Matkins on

According to the California Franchise Tax Board, a limited liability company classified as a partnership must do all of the following...more

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